When lawyers abandon clients
Maples v. Thomas
In brief
The Supreme Court ruled that Maples had cause for missing the appeal deadline, overturned the Eleventh Circuit’s ruling, and sent the case back for further proceedings.
- Where it stands
- Decided
Decided 7-2 · January 18, 2012 · Opinion by Justice Ginsburg
- What it’s about
- The Supreme Court ruled that Cory Maples had a valid excuse (“cause”) for missing Alabama’s deadline to appeal the denial of his state post-conviction petition because his lawyers had abandoned him without telling him.
- Who it affects
- The ruling establishes that Maples had cause to excuse his missed state appeal; it does not resolve his underlying claims.
Summary: written with AI from the case record.
What it's about
It overturned the appeals court’s ruling and sent the case back to the lower court (remanded).
The two lawyers representing Maples in his state post-conviction case left their firm for jobs that prevented them from continuing to represent him, but did not tell him. The notice of the denial later came back unopened.
Alabama’s Court of Criminal Appeals barred Maples’s state appeal because he did not file a notice of appeal within the allotted time.
Question presented
Did the Eleventh Circuit properly hold that there was no "cause" to excuse any procedural default when the petitioner was blameless for the default, the State's own conduct contributed to the default and the petitioner's attorneys of record were no longer functioning as his agents at the time of any default?
What the Court decided
Holding
Maples has shown the requisite “cause” to excuse his procedural default. 586 F. 3d 879, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court found Maples had a valid reason for missing the deadline: his lawyers had abandoned him without telling him. It concluded this was “cause” to excuse the procedural default, or failure to follow the state-court appeal rule.
The vote
From the opinions
“Because I cannot agree with that conclusion, and because Maples’ alternative argument fares no better, I would affirm the judgment.”
What's next
The case returns to the Eleventh Circuit for further proceedings. The Court decided only whether Maples had cause to excuse this procedural default; his underlying claims remain unresolved.
Documents
Opinions
Audio
Docket activity
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AI analysis generated: Case Briefing
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Audio Recording added: Oral Arguments - Maples
Opinion added: Maples
More questions
- What filing did Maples miss?
- He did not file a notice of appeal from the denial of his state post-conviction petition by Alabama’s deadline.
- What happened to the notice of the denial?
- Justice Alito said the firm failed to route it to another lawyer or the departed attorneys, and the envelope came back unopened.
- What was Justice Scalia’s position?
- He rejected the conclusion that the lawyers’ abandonment established cause and said he would have upheld the Eleventh Circuit’s judgment.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.